Investors who realize that skepticism and alternative viewpoints are healthy for markets could find no worse of a company than Biovail Corporation (NASDAQ: BVF).

Biovail decided it didn't like Bank of America analyst Jerry Treppel because he had the gall to downgrade the company's stock. The two parties ended up locked in litigation with Biovail claiming that Treppel had defamed then-chairman Eugene Melnyk. Treppel claimed that Biovail had tried to ruin his reputation.

Yesterday Biovail announced that it had settled all litigation with the former analyst. Of course, terms of the settlement were not disclosed but Biovail did add that they would not be material to the company's results.

Even without knowing the terms of the settlement, Mr. Treppel has certainly won the moral victory here. Back in March the company paid a $10 million fine as part of a settlement with the SEC related to accounting fraud. For an encore, the company pled guilty to involvement in a kickback and conspiracy scheme.

With this litigation out of the way, Biovail will be able to get back to what it does best: producing lackluster results that make shareholders wish they'd never heard of Biovail.